ML20115E269
| ML20115E269 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2020 |
| From: | David Garmon-Candelaria Office of Nuclear Reactor Regulation |
| To: | Binoy Desai, Anthony Dimitriadis, Steven Orth, Greg Warnick Office of Nuclear Reactor Regulation |
| Garmon-Candelaria D | |
| References | |
| Download: ML20115E269 (3) | |
Text
From: Garmon-Candelaria, David To: Dimitriadis, Anthony; Desai, Binoy; Orth, Steven; Warnick, Greg Cc: Hsueh, Kevin; Hipschman, Thomas; Smith, Micheal
Subject:
Supplemental Guidance for Reactor RP Inspections during COVID-19 PHE Date: Friday, April 24, 2020 9:46:00 AM Attachments: Supplemental Guidance Regarding IMC 2515 App E Application to Radiation Safety Inspections.pdf
- BCs, Please find the attached final version of the supplemental guidance for radiation protection inspections under IP71124 regarding the new IMC 2515, Appendix E. This document will be uploaded to ADAMS under ML20115E269.
Please reach out if you have questions.
- Best, Dave David Garmon Health Physicist and Radiation Safety Officer Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-3512 Need Dosimetry? Fill out an NRC Form 537 and email it to me.
Monitored by an outside organization? Use NRC Form 525 to request results and send results to me.
See NRC Collection of Abbreviations (NUREG-0544, Rev. 5) for standard abbreviations.
Supplemental Guidance Regarding IMC 2515 App E Application to Radiation Safety Inspections (COVID-19 Public Health Emergency [PHE])
Supplemental Guidance to IMC 2515, App E, Section 2515E-07.h: In the event of a national state of emergency or widespread implementation of aggressive social distancing, Regions should consider deferring/postponing all onsite inspection activities. Regions should assess inspection procedure objectives and licensee personnel support to determine whether procedures can be performed remotely.
Purpose The purpose of this guidance is to assist the Regions in their assessment of which inspection procedure objectives can be met (i.e., completed) through remote inspection efforts and which inspections can only be partially completed (i.e., performed) because they require on-site time in order to fully meet inspection objectives.
Considerations
- 1. The radiation safety inspection program, contain in IP 71124, is designed to be completed onsite, by qualified HP inspectors. It is performance-based; dependent on direct interactions with licensee personnel; and requires independent observations of licensee RP programs in practice.
- 2. The following radiation safety inspection requirements can be completed (i.e. all aspects of the requirement statements met) remotely with minimal impact on the quality of the inspection if properly supported by the licensee.
71124.02 Requirement 03.01 71124.04 Requirement 03.01*
71124.05 Requirements 03.02 and 03.03 71124.06 Requirements 03.02 - 03.04 71124.07 Requirements 03.02 and 03.03 71124.08 Requirements 03.03 and 03.05
- Remaining requirements can be completed remotely provided inspectors can address satisfy information security associated with records.
- 3. Only portions of inspection requirements not listed above can be performed and thus the inspections cannot be completed solely using remote inspection.
- 4. Remote inspection is heavily dependent on the licensees ability and willingness to support .
The burden on the licensee must be considered when determining if an inspection should be completed remotely. In many cases, even though an item is a candidate for a remote inspection, the level of effort required by the licensee to support an inspection that meets NRC standards can be substantial (e.g., additional documentation, videotaping events, teleconferencing etc.).
- 5. Seven of eight radiation safety procedures have inspection cycles of two or three years and thus can be deferred entirely until later in the inspection cycle without significant impact to the program objectives or licensees.
- 6. IP 71124.01 is the radiation safety inspection programs only annual procedure. This procedure is designed to be completed at a site engaged in an outage or significant radiological work. Five of the six requirements (requirements 03.02 thru 03.06) of IP 71124.01 have portions that require direct inspector observations, or significant recent inspector experience with the licensees program, to complete. These requirements should not be designated as having been completed solely through remote inspection. Rather, there are portions of the individual inspection requirements that can be performed remotely with ultimate completion dependent upon onsite follow-up at some later time. Recent experience performing IP 71124.01, at ANO and at Limerick indicates that the level-of-effort associated with this inspection was substantial on the part of the inspector and the licensee.
Note that significant inspector experience and knowledge of the RP program at Limerick enabled performance of the inspections. Without that experience/knowledge, only portions of the requirements can be performed with actual completion contingent upon onsite inspector follow-up in the future.
Guidance Per IMC 2515, App E, the Regions have the discretion to perform inspections remotely as supported by their own assessments. In general, Regional staff should defer completion of radiation safety inspections to a period when inspectors can resume normal access to sites (i.e.,
following the COVID-19 PHE) and to conclude that inspections which cannot be deferred to a later date (i.e. IP 71124.01 for sites that only have outages/significant radiological work scheduled during the mandatory telework time frame) will not be completed as planned during this inspection cycle. This will limit the burden on licensees during these unprecedented times while maintaining an appropriate level of oversight for NPP licensees.